Delhi High Court: SC/ST Candidates Cannot Claim Automatic Relaxation in SFIO Prosecutor Recruitment

In an important ruling, the Delhi High Court has clarified that candidates belonging to Scheduled Caste or Scheduled Tribe (SC/ST) categories do not have an automatic right to seek relaxation of eligibility criteria for appointment as prosecutors in the Serious Fraud Investigation Office (SFIO).

The case, Anant Kumar Rao v. Union Public Service Commission and Others, was decided by a Division Bench of Justice Anil Kshetarpal and Justice Amit Mahajan.

What Was the Case About?

The petitioner, Anant Rao, who belongs to the ST category, challenged the rejection of his application for the post of prosecutor in SFIO. The recruitment process was conducted by the Union Public Service Commission (UPSC) in 2022 for 20 prosecutor posts.

The eligibility criteria required at least two years of litigation experience.

Rao had mentioned two years and seven months of experience at a law firm. However, UPSC found that part of his experience was not supported by proper documents. After the cut-off date, he submitted additional certificates to support his claim and argued that, being an ST candidate, he was entitled to relaxation.

His plea was earlier dismissed by the Central Administrative Tribunal (CAT), and he approached the High Court against that order.

Court’s Key Observations

The Court made the following important points:

• Although UPSC has discretionary power to relax eligibility conditions for SC/ST candidates, this does not create a legal right in favour of any candidate.
• Relaxation cannot be claimed “as a matter of course.”
• The fact that a candidate belongs to the ST category does not automatically mean eligibility conditions must be relaxed.
• The cut-off date for submitting documents must be strictly followed.

The Court emphasised that allowing candidates to submit additional documents after the closing date would disturb fairness and equality in the recruitment process. It observed that such flexibility would violate Articles 14 and 16 of the Constitution of India, which guarantee equality before law and equal opportunity in public employment.

Experience Must Match Job Responsibilities

The Court also examined whether Rao’s experience met the essential requirement of litigation work. It noted that his work involved drafting and vetting commercial contracts but did not include court appearances.

Since the role of an SFIO prosecutor involves filing complaints and assisting in prosecution before courts, the Court held that litigation experience has a direct connection with the functional duties of the post.

Therefore, UPSC’s decision was neither arbitrary nor unreasonable.

Final Outcome

The Delhi High Court upheld the CAT’s order and refused to grant any relief to the petitioner.

The judgment reinforces that relaxation provisions for reserved category candidates depend on discretion and specific conditions, and do not amount to an enforceable entitlement.